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Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

As of: March 27, 2021

Table of contents

 

 


fidem. S.A.
291 rue de Rollingergrund
2441 Luxemburg

Authorized representatives:
Marlon-Yves Nadler

Contact:
Email: marlon.nadler@fidem.lu

Imprint:
https://www.fidem.lu/en/imprint/

Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact information (e.g., email, phone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. web pages visited, interest in content, access times).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

 

Categories of persons concerned

  • Employees (e.g. employees, applicants, former employees).
  • Business and Contractual Partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (e.g., website visitors, users of online services).

 

Processing purposes

  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Office and organizational procedures.
  • Direct marketing (e.g. by e-mail or postal mail).
  • Feedback (e.g. collecting feedback via online form).
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creation of user profiles).
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.

 

Relevant legal bases

The following is an overview of the legal basis of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – The processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

 

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL-Encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. Insofar as this transfer is for administrative purposes, the transfer of the data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Cookies use

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanente Cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-Party-Cookies: First-party cookies are set by ourselves.
  • Third-Party-Cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as “tracking”, i.e., tracking the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made by means of a variety of services, especially in the case of tracking, via the web pages https://optout.aboutads.info and https://www.youronlinechoices.com/ be declared. In addition, you can receive further objection notices within the scope of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers named in the cookie consent management procedure can be obtained and managed and revoked by the users. In this context, the declaration of consent is stored in order not to have to repeat its request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system and end device used.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g., website visitors, users of online services)..
  • RLEGAL BASIS: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data for the fulfillment of our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organization. We only disclose the data of the contractual partners to third parties within the scope of applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Kundenkonto: Contractual partners can create an account within our online offer (e.g. customer or user account, in short “customer account”). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when the customer account is terminated.

Economic analysis and market research: For business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take the privacy of the users into consideration and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).

More information about commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as “Customers”) in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and delivery or execution or performance.

The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)..
  • Affected persons: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Providing contractual services and customer service, contact requests and communications, office and organizational procedures, managing and responding to requests, security measures, conversion measurement (measuring the effectiveness of marketing activities), profiles with user-related information (creating user profiles).
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Email sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes.

Registration with clear name: Due to the nature of our community, we ask users to use our offer only by using clear names. I.e. the use of pseudonyms is not allowed.

Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to any legal permission, obligation or consent of the users.

It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Providing contractual services and customer service, security measures, administration and responding to requests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is made in order to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Affected persons: Communication partner.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed through conference platforms: In the course of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends on the one hand on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access,

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: Provide contractual services and customer service, contact requests and communications, office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Cloud Services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, employees (e.g., employees, applicants, former employees), prospects, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details, if these are required for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always done in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: The newsletter is sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

Contents: Information about us, our services, promotions and offers.

Measurement of open and click rates:

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which

Dispatch via SMS: The electronic notifications can also be sent as SMS text messages (or are sent exclusively via SMS if the sending authorization, e.g. a consent, only includes sending via SMS).

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Possibility of objection (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

 

Promotional communication via e-mail, mail, fax or telephone

We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.

After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Affected persons: Communication partner.
  • Purposes of processing:Purposes of processing: Direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Web analytics, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas require optimization.

In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there, and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)..
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Services used and service providers:

 
 
  • Google Ads, Remarketing and Conversion Tracking: We use the service Google Ads. Google Ads is an online advertising program of Google LLC, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). The responsible entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. This means that we place Google Ads ads and also use Google Remarketing and conversion tracking as part of this. The ads are displayed after search queries on websites of the Google advertising network. In addition, we use Ads remarketing lists for search ads. This allows us to customize search ad campaigns for users who have visited our website before. Through the services, we have the possibility to combine our ads with certain search terms or to display ads for previous visitors in which, for example, services are advertised that the visitors have viewed on our website. We can thus display interest-based advertising to users of our website on other websites within the Google advertising network (as a “Google Ad” within Google Search or on other websites).
  • For interest-based offers, an analysis of online user behavior is necessary. Google uses cookies to perform this analysis. When clicking on an ad or visiting our website, a cookie is set on the user’s computer by Google. These cookies have a term of 90 days. The information collected by means of the respective cookie is used to target the visitor in a subsequent search query. Further information on the cookie technology used can also be found in Google’s notes on website statistics and in the privacy policy. With the help of this technology, Google and we as a customer receive information about the fact that a user has clicked on an advertisement and has been redirected to our web pages. The information obtained in this way is used exclusively for statistical evaluation for ad optimization. We do not receive any information with which visitors can be personally identified. Your IP address is transmitted to Google, but since we use Google Analytics IP masking on this website, your IP address is anonymized. The statistics provided to us by Google include the total number of users who clicked on one of our ads and, if applicable, whether they were redirected to a page on our website that was tagged with a conversion tag. Based on these statistics, we can track which search terms were clicked on our ad particularly often and which ads lead to a contact via the contact form by the user.

  • You can find more information on data protection in the context of Google Ads at: https://policies.google.com/technologies/ads?hl=de

    Personal data is transferred to the US under the EU-US Privacy Shield based on the European Commission’s adequacy decision. You can access the certificate here:
    https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI

    The legal basis for the described data processing is your consent, Art. 6 para. 1 p. 1 lit. a DSGVO. Once you have given your consent, you can revoke it at any time with future effect by changing your selection in the cookie settings (see above, section 4. Cookies). Alternatively, you can delete your cookies (all or only from this website). The banner with the choices will then be displayed again.

    You also have the option of selecting the types of Google ads or deactivating interest-based ads on Google via the ad setting (https://adssettings.google.com/authenticated?hl=de).

 

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “Content”) based on users’ potential interests and measuring its effectiveness.

ZFor these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user data relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned data. We ask that you note that users can make additional agreements with the providers, e.g., by giving their consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Marketing, profiles with user-related information (creating user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Possibility of objection (Opt-Out): We refer to the data protection notices of the respective providers and the objection options (so-called “opt-out”) given for the providers. If no explicit opt-out option has been specified, it is possible to disable cookies in the settings of your browser. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:

 

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, the enforcement of the rights of the users could be made more difficult..

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”)..

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Services used and service providers:

  • Font Awesome: Display of fonts and symbols; service provider: Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Website: https://fontawesome.com/; Privacy policy: https://fontawesome.com/privacy.
  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website.: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Possibility of objection (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

 

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is limited to these purposes. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Our privacy notices may also contain further information on the retention and deletion of data, which will take precedence for the respective processing operations.

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right of rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data relating to you be deleted immediately or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request that it be transferred to another controller.
  • Beschwerde bei Aufsichtsbehörde: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR..

 

Definition of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • IP-Masking: “IP masking” refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing.
 
  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
 
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
 
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
 
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors’ behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
 
  • “Controller”: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
 
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.